ARCHIVED REPORTS_LIMITED PHASE II ENVIRONMENTAL SITE ASSESSMENT AND SUMMARY OF PROJECT TO DATE

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November 16,2005 NOA Project Number. E05120B 6.2 Recommendations Manure and manure-impacted soils remaining on the Site will continue to impact groundwater until removed. NOA recommends that additional investigation be performed into the depth and extent of the manure and manure-impacted soils on the Site. Backhoe trenching appears to be the most expeditious method of conducting this investigation. Additional investigatory methods may be required within the ponds. Confirmatory samples should be collected from the visually clean soil layers identified to confirm that elevated TKN is not present in those layers. It should be noted that the natural soil,manure, and manure-impacted soil may be problematic from a geotechnical standpoint In estimating volumes of impacted soil for removal,it may be advisable to perform a geotechnical investigation on the clean soil layers concurrent with the environmental trenching and sampling to determine whether they will be suitable for construction. Regarding the potential buried cow areas,NOA concurs with Mr. Huggins of the EHD that letters should be drafted by each of the owners and operators of the dairy indicating the locations of the buried cows. If the owners and operators are cooperative,then confirmatory trenching operations are warranted in the identified areas. Any carcases identified should be removed from the Site and appropriately disposed. The soil stains observed should be over-excavated under the oversight of a qualified professional and appropriately disposed. Based on the questionable past practices of the operators as raised by the lawsuit cited,NOA recommends that a qualified environmental professional be present during site grading activities to identify any additional sources of contamination which may be present. Following soil removal of the nitrogen source, additional groundwater investigation is tecommended,which may extend off-site to the east. The decision on whether to conduct further investigation into the groundwater contamination beneath the Site should be based on risk tolerance. Mr. Huggins has indicated that he is not particularly concerned with the nitrate contamination of groundwater at this time because the area will be placed on municipal water. Ms. Herbst of the Board has stated that the Board is not actively pursuing remediation of nitrate impacts at this time,but that does not preclude possible future requests for investigation. At the time that Clayton completes its on-site pipeline investigation and releases it,NOA will perform a review of the report. Further investigation into the pipelines may be warranted. The well and septic system on the Site should be properly abandoned under the oversight of the FED prior to Site development. The additional septic system which was previously abandoned but for which no abandonment documentation was found will require further investigation or a determination from the EHD regarding the status of its abandonment. HMS's recommendations,as described in the October 17,2005 report, should be followed for the abatement of asbestos-containing materials and lead-based paints. • 12